In this episode, Matt Kelly and I go into the weeds to consider the recent racial incident at Starbucks store in Philadelphia where two African-American males were arrested for criminal trespass while waiting for a third colleague to join them for a business meeting. They had not purchased any products but were not engaging any type of disruptive behavior. They were released with no charges filed.

We consider several points around this incident from the compliance perspective, including the lessons for compliance officers are really about the challenges of policy and procedure at large organizations. The gap between those two requirements is filled by employee judgment — and that is where things went awry. We consider if a single solution, such as  all seats and bathrooms are reserved for patrons who have already purchased a product, create more problems than they solve. We also review the underlying premise of ‘what is Starbucks’ to see if a more robust risk assessment process might have helped identify these gaps.

This week’s discussion is literally torn from recent headlines. It provides an excellent example of the many compliance challenges every business and CCO face.

For more reading, see Matt’s blog post Starbucks and Policy Management Perilsand Tom’s blog post Starbucks and Lessons for the Compliance Practitioner in Risk Management